Principles for Reuse in EPR & DRS
Updated July, 2025
With momentum surging in state legislatures to address our growing waste crisis, we face a pivotal opportunity to catalyze the new reuse economy. State legislation such as Extended Producer Responsibility (EPR) and Deposit Return Systems (DRS) must focus on transitioning to a circular economy that prioritizes reuse. The best solutions are place-based, which is why these principles include flexibility for policies to reflect each state’s unique needs.
Include reusable packaging as a covered material. Returnable and refillable packaging should be covered materials in EPR and DRS programs. This enables traceability, allows for financial incentives, and unlocks infrastructure investments.
Clearly define “reusable” packaging.
Returnable Reusable Packaging is designed to be recirculated multiple times for the same or similar purpose in its original format in a system for reuse, that is owned by producers or a third party and is returned to producers or a third party after each use.
Refillable Packaging is designed to be refilled by consumers multiple times for the same or similar purpose in its original format, and that is sold or provided to consumers once for the duration of its usable life.
Learn more here.
Institutionalize reuse by investing program funds into reuse systems.
Require producers to invest in reuse infrastructure and systems by directing pooled program funds toward a shared, interoperable system that leverages the recycling system to collect and sort reusables. Dedicate a portion of the overall program budget to developing and maintaining reuse systems every year.
Create convenient, self-reinforcing systems to maximize consumer participation, ideally with financial incentives to return or refill reusables and beverage containers. For example, deposits have been shown to be the most successful way to ensure consumers return reusables. Any consumer deposits should be covered by SNAP or other food assistance programs.
Learn more here.
Incorporate financial incentives for producers to transition to reusables within program fee structures.
Within base fees: Charge reusables only once, upon first market entry. Each time they are reused after this should be “free.”
Within eco-modulated fees: The cost to introduce reusables should be lower than cost to introduce comparable single-use packaging. Provide greater incentives for returnables than for refillables.
Mandate and measure reuse. EPR and DRS policies should set ambitious, time-bound, measurable targets to scale reuse effectively. Targets should be set in statute or regulations, or the program should create a mechanism for targets to be set and reassessed in the future, such as requiring producers to propose reuse targets through a stewardship plan. Targets should include:
Reuse market share: an overall market share of reusable packaging.
Return rate: an average annual return rate across reusable packaging.
Source reduction of single-use packaging: an aggregated reduction in the amount of single-use packaging introduced into the supply chain, relative to a recent baseline. Refill efforts can count toward source reduction rates, but reuse and return rates should be set and tracked separately.
Enact DRS and EPR as complementary policies. Ideally, DRS should come before EPR or at the same time. DRS builds out infrastructure for collection, washing, and redistribution of reusable beverage containers that is crucial for scaling reuse. Additionally, deposits or other financial incentives are proven ways to ensure that consumers return reusable packaging into the right collection systems. Learn more here.
Center justice and equity in process and content. Develop policies inclusively and ensure continued, meaningful community engagement — especially of low-income communities and communities of color - throughout program implementation. Prioritize the prevention and mitigation of environmental and health impacts from waste management, disposal, and litter in frontline communities, and ensure equitable access to reuse and recycling.
Allow flexibility; avoid barriers to reuse. Minimize barriers to the nascent reuse sector by encouraging competition, correcting outdated food codes and other conflicting policies, and avoiding overly burdensome reporting and other administrative requirements on reuse operators.
Ensure transparency. Producers in EPR and DRS systems should be required to report, via their producer responsibility organizations or individually:
Progress toward reuse and source reduction targets
The amount of returnable and refillable packaging on the market (separately)
Return rates & loss rates for reusable packaging
Packaging & waste reduction from reuse
Waste material flows (where are reusables ending up?)
Financial contributions to reuse systems
Selection procedures for reuse service providers
Member brands with reusables on the market
Each reusable packaging offering in the state
You can download a PDF copy of these Principles here.